Privacy Policy

> Privacy Policy

Ringgold respects your privacy. We receive and store any information you enter on our Web site or give us in any other way in order to monitor activity, but we do not re-distribute this information to third parties unless pursuant to a written agreement including terms compliant with the Swiss-U.S. Privacy Shield and/or U.S.- EU Privacy Shield Framework and/or EU General Data Protection Regulation. We receive and store certain types of information whenever you interact with us. We use “cookies”, and we obtain certain types of information (such as IP addresses) when your Web browser accesses our website.

How we use Cookies

Like many Web sites, we use a cookie for some of our services to store your state information about where you are in the site, as well as to track current and past activity. Ringgold does not store any of your personal information in cookies.

If you turn off cookies in your browser, then the service we provide from the site will be affected and you may be forced to log in every time you visit the site.

Ringgold will never read or attempt to read cookies other than those written by its own services.

Why we store information

Most of the information we collect is analyzed so that we can improve the user interface and to insure there is no misuse of the web site. Search history information is used to maintain accounting charges and as a statistical aid to improve searches or as a diagnostic aid for problem solving. Such information is not shared outside of Ringgold. When necessary we will use your information to contact you. We may send promotional emails occasionally.

What information is stored

Your Personal or organizational information. What information is stored depends on a user category, typically one of two types:

Registered user

A registered user provides one’s email address, IP address, organizational name and type of organization to Ringgold for our statistical and communication purposes. This information cannot be used to analyze searching histories.

Once registered, cookies are used to store information about the number of available searches the user can make. Information about the user’s “state” is also kept in cookies to enable the system to maintain “session” information as the user moves about the site and makes database searches.

Subscriber

Such an account user is an individual belonging to an organization paying a subscription to Ringgold for additional searching and reporting services. In addition to the information for registered users, the individual account user has a personal name, a logon name and password, one’s organizational affiliation, an IP address, and related search history information stored. Other data stored can include phone numbers and email addresses.

Other information

In order to improve its Services, Ringgold, from time to time, may require additional information or use the information gathered in other ways than listed above. The purpose of any additional information requested will always be explained and your consent gained before use.

Disclosure statement

Personal or organizational information will not be used for reasons other than stated in this document. Ringgold will not disclose personal or organizational information to a third party, except to fulfill the purposes you have authorized in a written agreement or if required by law.

Ringgold complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of (called Personal Data under the GDPR) transferred from the European Union and Switzerland to the United States. Ringgold has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Ringgold is responsible for the processing of Personal Data it receives, under the U.S. Privacy Shield Framework or EU General Data Protection Regulation, and subsequently transfers to an independent third party acting on its behalf. Ringgold and any independent subcontractors comply with the Privacy Shield Framework or EU General Data Protection Regulation for all onward transfers of Personal Data from the EU.

With respect to Personal Data received or transferred from the EU to the U.S. Privacy Shield Framework, Ringgold is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Ringgold may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Scope

This Privacy Policy (the “Policy”) applies to all Personal Data received from consumers by Ringgold in the United States from the EU or Switzerland, in any format including electronic, paper or verbal.

Privacy Shield Framework

In compliance with the Privacy Shield Principles, Ringgold commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact Ringgold at:

Ringgold has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

Definitions

For purposes of this Policy, the following definitions shall apply: “Subcontractor” means a legally independent third party that collects or uses Personal Data under the instructions of Ringgold or to which Ringgold discloses Personal Data for use on Ringgold’s behalf. “Ringgold” means Ringgold Inc. in the U.S. and Ringgold Ltd. in the UK, its successors, subsidiaries, divisions and groups in the United States. Personal Data mean any information or set of information that identifies or is used by or on behalf of Ringgold to identify an individual. Even though Personal Data may be encoded or anonymized, it is still subject to the requirements of the GDPR and U.S.-EU Privacy Shield Framework. It also covers publicly available and public domain information. Personal Data “Sensitive Personal Data” means Personal Data that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Ringgold will treat as sensitive Personal Data any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

NOTICE: Where Ringgold collects Personal Data directly from individuals in the EU, it will inform them about the purposes for which it collects and uses Personal Data about them and the choices and means, if any, Ringgold offers individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to Ringgold, or as soon as practicable thereafter, and in any event before Ringgold uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a third party.

Where Ringgold receives Personal Data from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Data relates.

CHOICE: For Personal Data and Sensitive Personal Data, Ringgold will offer individuals the opportunity to choose (opt-in) whether their Personal Data is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. In other cases, where Personal Data is incorporated in data sets transferred from institutional customers, consent will be obtained by those institutional customers or processing will commence only after a Legitimate Interest pursuant to the GDPR or U.S.-EU Privacy Shield Framework is identified.

Ringgold will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Ringgold will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual or institutional entity client. Ringgold will take reasonable steps to ensure that Personal Data is relevant to its intended use. We will only collect and store Personal Data that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of the request.

TRANSFERS TO THIRD PARTY PROCESSORS: Ringgold will obtain assurances from its independent third party subcontractors that they will safeguard Personal Data consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the subcontractor to provide at least the same level of protection as is required by the relevant U.S. Privacy Shield Framework or EU General Data Protection Framework, being subject to same level of privacy certification by the subcontractor, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Ringgold has knowledge that an agent is using or disclosing Personal Data in a manner contrary to this Policy, Ringgold will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Ringgold will grant individuals reasonable access to Personal Data that it holds about them. In addition, Ringgold will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by completing our International Consumer Service form at https://www.ringgold.com/contact or by calling the Ringgold office in the country where they reside and asking for consumer services.

SECURITY: Ringgold will take reasonable precautions to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Ringgold will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Ringgold determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of Personal Data should be directed to the Ringgold Office of Ethics and Business Conduct at the address given below. Ringgold will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the principles contained in this Policy. Ringgold has chosen the EU Data Protection Authorities (EU DPAs) to serve as an independent recourse mechanism (IRM) for dispute resolution arising from collection, use, and retention of Personal Data transferred from EU member countries to companies in the United States and has remitted the following fee to USCIB, acting as a trusted third party on behalf of the European Union (EU) Data Protection Authorities.

LIMITATIONS ON APPLICATION OF PRINCIPLES: Adherence by Ringgold to the U.S. Privacy Shield Framework or EU General Data Protection Regulation may be limited (a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation.

Internet Privacy

Ringgold sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. Ringgold recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the “IPP”) governing the treatment of Personal Data collected through web sites that it operates. With respect to Personal Data that is transferred from the European Union or Switzerland to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. Ringgold’s Internet Privacy Policy can be found at https://www.ringgold.com/privacy.

Contact Information

Questions or comments regarding this Policy should be submitted to the Ringgold Office of Ethics and Business Conduct by mail as follows:

Changes to this Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the U.S. Privacy Shield Framework or EU General Data Protection Regulation. A notice will be posted on the Ringgold web page (www.ringgold.com) for 60 days whenever this Privacy Policy is changed in a material way.

Effective Date

April 18 2018

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